Viral DRM LLC v. Maryna Lietucheva

CourtDistrict Court, N.D. California
DecidedJanuary 17, 2024
Docket3:23-cv-04300
StatusUnknown

This text of Viral DRM LLC v. Maryna Lietucheva (Viral DRM LLC v. Maryna Lietucheva) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Viral DRM LLC v. Maryna Lietucheva, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 VIRAL DRM LLC, Case No. 3:23-cv-04300-JSC

8 Plaintiff, ORDER DENYING MOTION FOR 9 v. DEFAULT JUDGMENT; AND ORDER TO SHOW CAUSE RE: PERSONAL 10 MAXIM ONYSHCHUK, a.k.a. CLIMATE JURISDICTION AND JOINDER CHANGE, et al., 11 Re: Dkt. No. 60 Defendants.

13 Plaintiff Viral DRM LLC syndicates and licenses video content of extreme weather events 14 from around the world. Plaintiff brings copyright infringement claims against eight Defendants. 15 Defendants, who are foreign citizens, allegedly downloaded and copied Plaintiff’s copyrighted 16 materials from YouTube, and then re-uploaded infringing versions of Plaintiff’s copyrighted 17 media content to their YouTube channels. The Court previously granted Plaintiff’s motion for a 18 temporary restraining order (TRO) and motion for alternative service. (Dkt. Nos. 20, 21.1) 19 Plaintiff served Defendants via email on October 18, 2023 and the Court converted the TRO into a 20 preliminary injunction on November 2, 2023. (Dkt. Nos. 44, 49.) After no Defendant appeared, 21 the Clerk entered their default and Plaintiff’s motion for default judgment is now pending before 22 the Court. (Dkt. Nos. 56, 60.) After carefully considering the arguments and briefing submitted, 23 the Court concludes that oral argument is unnecessary, see Civ. L.R. 7-1(b), and DENIES the 24 motion for preliminary injunction. Plaintiff has failed to meet its burden of demonstrating the 25 Court has personal jurisdiction over Defendants. 26 27 1 DISCUSSION 2 Under Federal Rule of Civil Procedure 55(b)(2), a plaintiff may apply to the district court 3 for—and the court may grant—a default judgment against a defendant who has failed to plead or 4 otherwise defend an action. See Draper v. Coombs, 792 F.2d 915, 925 (9th Cir. 1986). Courts 5 have a duty to examine both subject matter and personal jurisdiction when default judgment is 6 sought against a non-appearing party. In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999). 7 A. Jurisdiction 8 The Court has federal question subject matter jurisdiction over Plaintiff’s copyright 9 infringement claims under 17 U.S.C. § 501. See 28 U.S.C. § 1331. Plaintiff, however, has not met 10 its burden of establishing personal jurisdiction over the nonresident defendants here. See Doe v. 11 Unocal Corp., 248 F.3d 915, 922 (9th Cir. 2001). “For a court to have specific personal 12 jurisdiction in an intentional tort or copyright case, “the defendant allegedly must have (1) 13 committed an intentional act, (2) expressly aimed at the forum state, (3) causing harm that the 14 defendant knows is likely to be suffered in the forum state.” Mavrix Photo, Inc. v. Brand Techs., 15 Inc., 647 F.3d 1218, 1228 (9th Cir. 2011). Further, where there are multiple defendants, “[t]he 16 jurisdictional inquiry must decouple defendants, considering whether each individual defendant 17 has had sufficient ‘minimum contacts’ with the forum state to justify an exercise of jurisdiction.” 18 See Burri Law PA v. Skurla, 35 F.4th 1207, 1213 (9th Cir. 2022). 19 Plaintiff’s motion for default judgment makes no such showing. First, the motion itself is 20 self-contradictory and incomplete. Plaintiff contends on the one hand “[a]ll of The YouTube 21 Uploaders are foreign citizens,” while also arguing the Court “has personal jurisdiction over The 22 YouTube Uploaders because they are domiciled in California. The YouTube Uploaders’s principal 23 place of business is at . Therefore, this Court has personal jurisdiction over The YouTube 24 Uploaders.” (Compare Dkt. No. 60-1 at 12 with Dkt. No. 60-1 at 13.) Second, to the extent 25 Plaintiff intends to argue express aiming based on “allegedly displaying copyright protected 26 photos via videos uploaded to YouTube from [foreign locations]” this conduct is not sufficient to 27 “create a substantial connection with [California].” Werner v. Dowlatsingh, 818 F. App’x 671, 672 1 California—is not an act expressly aimed at California simply because the company is based in the 2 state.” Id. at 672 n.1. Finally, while the Complaint alleges “defendant [sic] are subject to personal 3 jurisdiction in this district, and because defendants consented to this venue when defendants 4 provided the counternotification(s) referred to herein because the service provider provided with 5 the counternotification(s) can be found in this judicial district,” Plaintiff’s submission represents 6 only three of the eight Defendants served counternotices, and, in any event, the motion for default 7 judgment makes no personal jurisdiction argument regarding the counternotices. (Dkt. No. 1 at ¶ 8 11; Dkt. No. 1-4; Dkt. No. 60-6.) 9 Accordingly, Plaintiff has not met its burden of demonstrating personal jurisdiction over 10 Defendants. The Court thus need not consider whether default judgment is proper under Rule 11 55(b) and the Eitel v. McCool, 782 F.2d 1470, 1471-72 (9th Cir. 1986), factors. See Vachani v. 12 Yakovlev, 2016 WL 1598668, at *3 (N.D. Cal. Apr. 21, 2016) (“The court cannot enter a default 13 judgment unless it has jurisdiction over both the subject matter and the parties.”). Plaintiff’s 14 motion for default judgment is DENIED. 15 B. Preliminary Injunction 16 In light of the Court’s concerns regarding personal jurisdiction, the Court DISSOLVES the 17 preliminary injunction as to the Defendants who did not serve counternotices. (Dkt. No. 49.) The 18 preliminary injunction order remains in place only as to the three Defendants who served 19 counternotices: Extreme Weather&Natural Disasters, NA Weather, and WAHR. (Dkt. No. 1-4; 20 Dkt. No. 60-6.) 21 C. Misjoinder 22 The Court also has concerns as to whether all Defendants are properly joined in this action. 23 Under Federal Rule of Civil Procedure 20, a plaintiff may join defendants in one action if:

24 (A) any right to relief is asserted against them jointly, severally, or in the alternative with respect to or arising out of the 25 same transaction, occurrence, or series of transactions or occurrences; and 26 (B) any question of law or fact common to all defendants will arise in the action. 27 Fed. R. Civ. P. 20(a)(2). Both prongs must be satisfied. See Visendi v. Bank of Am., N.A., 733 1 F.3d 863, 870 (9th Cir. 2013). The misjoinder issue may be raised by the court sua sponte. Fed. 2 R. Civ. P. 21 (“On motion or on its own, the court may at any time, on just terms, add or drop a 3 party”). 4 The Court’s review of the complaint demonstrates the first requirement is not satisfied: 5 Plaintiff does not allege each defendant is jointly, severally, or in the alternative liable for the 6 infringement of another defendant arising out of the same transaction, occurrence, or series of 7 transactions or occurrences.

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Related

Mavrix Photo, Inc. v. Brand Technologies, Inc.
647 F.3d 1218 (Ninth Circuit, 2011)
Gary R. Eitel v. William D. McCool
782 F.2d 1470 (Ninth Circuit, 1986)
Robert Draper v. Davis S. Coombs
792 F.2d 915 (Ninth Circuit, 1986)
Golden Scorpio Corp. v. Steel Horse Bar & Grill
596 F. Supp. 2d 1282 (D. Arizona, 2009)
DirecTV, Inc. v. Leto
467 F.3d 842 (Third Circuit, 2006)
Burri Law Pa v. William Skurla
35 F.4th 1207 (Ninth Circuit, 2022)
Doe v. Unocal Corp.
248 F.3d 915 (Ninth Circuit, 2001)

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Bluebook (online)
Viral DRM LLC v. Maryna Lietucheva, Counsel Stack Legal Research, https://law.counselstack.com/opinion/viral-drm-llc-v-maryna-lietucheva-cand-2024.